PB94-964057
                                  EPA/ROD/R04-94/186
                                  September 1994
EPA  Superfund
       Record of Decision:
        Naval Air Station, Cecil Field,
        Jacksonville, FL,
        9/14/1994

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                             REGION  IV

                       345 COURTLAND STREET. N.E.
                        ATLANTA. GEORGIA 3O365
                           SEP 14 1994
4WD-FFB

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Captain Kirk T. Lewis
Commanding Officer, NAS Cecil Field
P.O. Box 108 (code 00)
Cecil Field, Florida 32215-0108

SUBJ:  Cecil Field Site 11

Dear Captain Lewis:

     The Environmental Protection Agency  (EPA) has  received and
reviewed the final Interim Record of Decision  (IROD)  for  the
pesticide disposal area, also known as Site  11.  EPA concurs
with the Navy's decision as set forth in  the IROD'dated
September 1, 1994.  This concurrence is with the understanding
that the proposed action is an interim action  and the need for
any future or final remedial action will  be  addressed following
the finalization.of the Baseline Risk Assessment  (BRA) .

     By providing concurrence on this plan EPA does not warrant
technical adequacy as set forth or implied in  the IROD.
Additionally, EPA concurrence does not implicitly or expressly
waive any of it's rights or authority.

     EPA appreciates the opportunity to work with the Navy on
this site and other sites at Cecil Field.  Should you have any
questions, or if EPA can be of any assistance, please contact Mr.
Baft Reedy, of my staff, at the letterhead address  or at  (404)
347-3555 vmx 2049.


                                Sincerely,
                                Patrick M. Tobin, Deputy
                                Regional Administrator
cc:  Mr. James Crane,   FDEP
     Mr. Eric Nuzie,    FDEP
     Mr. Michael Deliz, FDEP
     Mr. Steve Wilson,  SDIV

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     INTERIM RECORD OF DECISION

GOLF COURSE PESTICIDE DISPOSAL AREA
        SITE 11, OPERABLE UNIT 6

     NAVAL AIR STATION CECIL FIELD
        JACKSONVILLE, FLORIDA
   Unit Identification Code (UIC): N60200

      Contract No. N62467-89-D-0317
               Prepared by:

       ABB Environmental Services, Inc.
       2590 Executive Center Circle, East
          Tallahassee, Florida 32301
               Prepared for:

    Department of the Navy, Southern Division
     Naval Facilities Engineering Command
              2155 Eagle Drive
     North Charleston, South Carolina 29418

   Alan Shoultz, Code 1875, Engineer-in-Charge


               August 1994

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Section
                               TABLE OF  CONTENTS

                                Interim Record of Decision
                        Golf Course Pesticide Disposal Area, Site 11, OU 6
                             MAS Cecil Reid, Jacksonville, Rorida
                         Title
Page No.
1.0  DECLARATION FOR  THE  INTERIM RECORD OF DECISION
      1.1
      1.2
      1.3
                                           	1-1
SITE NAME AND LOCATION	1-1
STATEMENT OF BASIS AND  PURPOSE  	   1-1
ASSESSMENT OF THE SITE	1-1
      1.4   DESCRIPTION OF THE SELECTED REMEDY  	
      1.5   STATUTORY DETERMINATIONS  	
      1.6   SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY

2.0  DECISION SUMMARY 	
      2.1
      2.2
      2.3
      2.4
      2.5
      2.6
      2.7
      2,
      2,
SITE NAME, LOCATION, AND  DESCRIPTION  	
SITE HISTORY AND ENFORCEMENT ACTIVITIES 	
PREVIOUS INVESTIGATIONS  	
HIGHLIGHTS OF COMMUNITY PARTICIPATION 	
SCOPE AND ROLE OF INTERIM REMEDIAL ACTION 	
SITE CHARACTERISTICS   	
SUMMARY OF SITE RISKS  	
DESCRIPTIONS OF ALTERNATIVES  	
SUMMARY OF COMPARATIVE ANALYSES  OF ALTERNATIVES 	  2
2.9.1 Overall Protection   	  2
2.9.2 Compliance with Applicable or Relevant and
      Appropriate Requirements (ARARs)  	  2-
2.9.3 Long-term Effectiveness and Permanence  	  2-
2.9.4 Reduction of Toxicity,  Mobility, or Volume of
      the Contaminants	2-
              ,9.5 Short-Term Effectiveness  	  2
              ,9.6 Implementability  	  2
        10
        11
      2.12
  9.7 Cost	2
  9.8 State and Federal Acceptance  	 2
  9.9 Community Acceptance   	 2
SELECTED REMEDY  	 2
STATUTORY DETERMINATIONS   	 2
DOCUMENTATION OF SIGNIFICANT CHANGES  	 2
     1-1
     1-2
     1-2

     2-1
     2-1
     2-1
     2-4
     2-7
     2-7
     2-7
     2-8
     2-8
     -10
     -10

     -10
     -10

      10
      22
      22
      22
      22
      22
      22
      22
      23
REFERENCES

APPENDIX A:  Responsiveness  Summary
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                                 LIST OF FIGURES
                                 Interim Record of Decision
                         Golf Course Pesticide Disposal Area, Site 11, OU 6
                              MAS Cecil Field, Jacksonville, Florida
Figure	Title	Page No.

2-1   Site  Location Map	2-2
2-2   Study Area	2-3
2-3   Locations of Anomalies  Test Pitted During Focused Remedial
      Investigation 	  2-5
                                  LIST OF TABLES
Table	Title	Page No.

2-1   Results of Product  and Soil Analyses  for Focused Remedial
      Investigation	2-6
2-2   Alternatives Evaluated for the Interim Remedial Action  at  Site 11  .  2-9
2-3   Comparative Analyses  of Source Control Remedial Alternatives  .  .   . 2-11
2-4   Synopsis of Potential Federal and State Action-Specific ARARs .  .   . 2-16
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                                   GLOSSARY
AOC         area of concern
ARARs       applicable or relevant and appropriate requirements

bis         below land surface

CAA         Clean Air Act
CAMU        corrective action management units
CERCLA      Comprehensive Environmental Response, Compensation, and Liability
            Act
CFR         Code of Federal Regulations

FAC         Florida Administrative Code
FDEP        Florida Department of Environmental Protection
FDER        Florida Department of Environmental Regulation
FFS         Focused Feasibility Study
FIFRA       Federal Insecticide, Fungicide, and Rodenticide Act
FS          Feasibility Study

IAS         Initial Assessment Study
IROD        Interim Record of Decision
LDR

mg/kg
/ig/kg
MSDS

NAS
NAAQS
NCP
NPL
NSPS
            Land Disposal Restrictions

            milligrams per kilogram
            micrograms per kilogram
            micrograms per liter

            Material Safety Data Sheets

            Naval Air Station
            National Ambient Air Quality Standards
            National Oil and Hazardous Substances Pollution Contingency Plan
            National Priority List
            New Source Performance Standards
OSHA
OU

PEL
ppb
PPE

RCRA
RFI
RI
ROD
            Occupational Safety and Health Administration
            Operable Unit

            permissible exposure limit
            parts per billio.n
            personal protection equipment

            Resource Conservation and Recovery Act
            RCRA Facility Investigation
            Remedial Investigation
            Record of Decision
SARA
            Superfund Amendments and Reauthorization Act
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                              GLOSSARY  (Continued)


TSD          treatment, storage, and disposal
TU           temporary units

USEPA        U.S.  Environmental Protection Agency

VOCs         volatile organic compounds

yd3          cubic yards
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              1.0  DECLARATION FOR THE INTERIM RECORD OF DECISION
1.1  SITE NAME AND LOCATION.  The site name is the Golf Course Pesticide Disposal
Area, Site  11,  Operable Unit  (OU)  6.  The  site  is located  in  a wooded area
between the llth fairway and the 17th  green at'the Naval Air Station  (NAS) Cecil
Field golf course, Jacksonville, Florida.


1.2  STATEMENT  OF BASIS  AND PURPOSE.   This  decision document  presents  the
selected interim remedial action for source control at OU 6 or Site 11, the Golf
Course Pesticide Disposal Area.  The selected interim remedial action was chosen
in accordance with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act  (CERCLA), as amended by the Superfund Amendments
and  Reauthorization  Act of  1986  (SARA), and  the National  Oil  and Hazardous
Substances Pollution Contingency Plan  (NCP, 40 Code of Federal Regulations [CFR] ,
Part 300).   This decision document explains the factual basis  for  selecting the
interim  remedy  for  Site  11 and  the  rationale for  the final decision.   The
information supporting this interim remedial action decision is contained in the
Administrative Record for this site.

The purpose  of  the interim remedial  action  is  to  remove  buried containers of
pesticides and associated contaminated soil.  The U.S.  Environmental Protection
Agency (USEPA)  and the Florida Department of  Environmental Protection (FDEP)
concur with the selected interim remedy.


1.3  ASSESSMENT  OF  THE  SITE.    Actual  or  threatened releases  of hazardous
substances from the site, if not addressed by implementing the response actions
selected in the Interim Record of Decision (1ROD), may  present an imminent and
substantial  endangerment to public health,  welfare,  or  the  environment  as a
result of concentrations of contaminants  in  soil  and groundwater in excess of
health-based  levels,  if the contents  of the containers  is  released  into the
environment.
1.4  DESCRIPTION OF THE SELECTED REMEDY.  The preferred alternative for source
control at Site 11 is a combination of two alternatives (Alternatives 1 and 3)
that were developed and evaluated in the Focused Feasibility Study  (FFS).   The
combined preferred alternative would meet the Resource Conservation  and Recovery
Act  (RCRA)  Land Disposal  Restriction (LDR)  requirements.   A  combination of
Alternatives 1 and 3 would involve:

     •  excavation of contaminated debris (i.e., empty, partially full, full, or
        leaking pesticide containers);

     •  repackaging   (overpacking)   of   full,   partially  full,  and  leaking
        containers  in an  area where spills  are  controlled with subsequent
        sampling of contents for waste profiling;

     •  excavation of contaminated soil;

     •  testing of excavated soils to determine if treatment is required prior
        to disposal (i.e., if the soils are subject to LDRs);


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     •  onsite treatment of contaminated debris (i.e., empty containers) using
        high pressure water washing;

        transportation and disposal of  decontaminated debris  to a solid waste
        landfill;

        transportation of full,  partially full, or leaking pesticide containers
        for offsite incineration;

     •  transportation and disposal of  soil  with  concentrations below the LDR
        treatment standards to a hazardous waste landfill;

        transportation, treatment,  and disposal in a hazardous waste landfill of
        all soil with concentrations of hazardous constituents that are higher
        than the LDR treatment standards;

     •  transportation, treatment (if necessary),  and disposal  of water used in
        high pressure water washing of hazardous debris;  and

     •  backfilling of excavated areas with clean soil.

The Navy estimates that the preferred alternative would cost between $708,000 and
$1,772,000 and would take 5 weeks to implement.  The  range in cost is dependent
on  the amount  of  excavated  material  that  has  concentrations  of  hazardous
constituents above  the LDR treatment  standard  and,  therefore,  must be treated
prior to land disposal.


1.5  STATUTORY DETERMINATIONS.  This interim action is protective of human health
and the environment, complies with Federal and State  applicable or relevant and
appropriate requirements  (ARARs) for this limited  scope action, and  is cost
effective.  Although this  interim  action is  not  intended to fully address the
statutory mandate for permanence and treatment to the maximum  extent practicable,
this interim action  uses treatment and, thus,  is in furtherance of that statutory
mandate.  Because this  action does  not constitute  the final  remedy for soil and
groundwater at Site  11, the statutory preference for remedies that employ treat-
ment that reduces toxicity, mobility, or volume as  a principal element, although
partially addressed in this remedy, will  be addressed by  the final response
action for soil and groundwater.   Subsequent actions are planned to address fully
the threats posed by the conditions in the soil and groundwater at this site.

Because this is an interim action Record of Decision  (ROD),  review of this site
and of this remedy  will be ongoing  as the Navy continues to  develop final
remedial alternatives for this site and this OU.
1.6  SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY
                                                               I
Captain Kirk T. Lewis   // I
Commanding Officer, NAS^ecil Field                          Date


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                             2.0  DECISION SUMMARY
2.1  SITE NAME. LOCATION. AND DESCRIPTION.   NAS  Cecil  Field  is located 14 miles
southwest of Jacksonville in the northeastern part of Florida.  Most of NAS Cecil
Field is located within Duval County; however, part is located in the northern
part of Clay County.

NAS Cecil Field was established in 1941 and provides facilities, services, and
material support for the operation and maintenance of naval weapons, aircraft,
and other units  of the operating  forces  as designated by  the  Chief of Naval
Operations.    Some of  the tasks required  to accomplish this mission include
operation of fuel  storage facilities, performance  of  aircraft maintenance,
maintenance and operation of engine repair  facilities  and test cells for turbo-
jet engines, and support of special weapons systems.

Site 11 is located in a wooded area on the golf course within the NAS Cecil Field
property as  shown on Figure 2-1.   The area  around Site 11 is covered with dense
undercover.   An  access road and  several  small  trails that  traverse the area
appear to be well  maintained and  free  of  vegetation.   The  greens and fairways
located  east and  west  of Site  11  are  flat and  grassy.    The  golf  course
maintenance  area  located  southeast of  the  site consists  of   several  small
buildings and sheds with asphalt and  concrete ground cover.   A sketch  of Site 11
is provided on Figure 2-2.

Surface runoff in  the immediate vicinity of Site 11 flows into the golf course
drainage system,  which eventually  drains to Rowell Creek.  There  is little to no
surface runoff at  the site itself due to the dense vegetation.


2.2  SITE HISTORY  AND ENFORCEMENT ACTIVITIES.  Site 11 was used by golf course
maintenance  personnel  for  the  disposal  of empty,  partially full,  and full
pesticide  containers  from the  early  1970's until  1978.    Containers  were
reportedly buried in a pit approximately 40 feet wide by 40 feet  long.  This pit
was reportedly (Envirodyne Engineers, 1985) located at the golf course between
fairways 11 and 17 (Figure 2-2).

Previous studies  indicated that approximately two to four  empty 5-gallon cans
were disposed  per month within the  pit.    The  cans  were not rinsed prior to
disposal. The  cans were allowed to accumulate for a number of months before they
were crushed by a front-end loader and buried approximately 3 feet deep.  It was
estimated that a  total of 200 to 450 containers were crushed  and disposed within
the pit.

After completion of the  new pesticide  facility  (Building 397) in 1978,  2 to 3
full 30-gallon containers  of unused pesticides,  at least 1 of which reportedly
contained l,2-dibromo-3-chloropropane (trade name Nemagon"1) ,  a pesticide used to
control nematodes, and  approximately 10 to 15 full or partially full 5-gallon
containers of pesticides, herbicides, and fungicides were discarded and buried
at  the site  because  they were  considered  unusable for  the   new  facility.
Reportedly,  many  of these containers were beginning  to  rust and lacked iden-
tification labels.  Once the move was made to the new facility,  use of Site 11
for container  disposal purposes was discontinued (Harding  Lawson Associates,
1988).

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     LAKE
                                                                                                    I
                                                                                                   N

                                                                                                   A
                     INSTALLATION BOUNDARY
                                                                                      3500    7000
                                                                               SCALE: 1" =  7000'
   FIGURE 2-1
   SITE LOCATION MAP
  CECIL/DECISION.dwg/NP/4- 28-9*
                    INTERIM RECORD OF DECISION
                    SITE 11
                                                                       NAS CECIL FIELD
                                                                       JACKSONVILLE, FLORIDA
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MVL08.94
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   FIGURE 2-2
   STUDY AREA
  CECIL\11MAP\?-WDW\08-24-94
                    INTERIM RECORD OF DECISION
                    SITEtl
                                                                     MAS CECIL FIELD
                                                                     JACKSONVILLE, FLORIDA
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To date there has been no enforcement activities at the site.


2.3  PREVIOUS INVESTIGATIONS.  Previous environmental  investigations  at Site 11
include an Initial Assessment Study  (IAS) , an RCRA Facility Investigation  (RFI),
and a Focused Remedial Investigation (RI).   The  results of these investigations
are summarized below.

Initial Assessment Study. The IAS was performed in 1985 by Envirodyne Engineers
to identify waste sites at NAS Cecil Field that warranted further investigation.
The study included an investigation  of historical data and aerial photographs as
well as field inspections and personnel interviews.   A  total of 18 sites were
identified as a result of the IAS,  including Site 11.

RCRA Facility Investigation.   The RFI  was  performed in  1988 by Harding Lawson
Associates.  Field investigations completed for Site 11 included a geophysical
survey using a. magnetometer to locate subsurface features, the installation of
two monitoring wells, collection and analysis of two groundwater samples and two
soil samples,  and measurement  of  water levels  in the two  monitoring wells.
Groundwater samples  contained inorganics such as chromium (332 and 40 micrograms
per liter [ng/$.]) and lead (573 and  59 fig/Ji").  The analytical results  of the two
soil  samples collected  from  the   suspected  pesticide  container burial  pit
indicated the presence of volatile  organic compounds  (VOCs) such as methylene
chloride (24 micrograms  per  kilogram  [A«g/kg]),  toluene  (16  Mg/kg), and 1,1,1-
trichloroethane (24  and  39 /zg/kg).

Focused Remedial Investigation.  A  Focused RI at Site 11 was conducted by ABB
Environmental Services,  Inc.,  from  July to October 1993  to  define the volume,
location, and characteristics of the reportedly buried  pesticide containers.
This investigation was accomplished by clearing the understory and vegetation,
conducting a geophysical survey to verify  the presence  of  disturbed soil and
identify anomalies,  test  pitting anomalies to characterize the contents, sampling
and analyses of pesticide products found in partially full or  leaking containers,
and  sampling and  analyses  of  soil  suspected of pesticide  contamination.
Approximately 40 percent of the areal extent of  the site was  investigated using
modified Level D personal protection equipment (PPE).  The remaining 60 percent
of the  work was -executed in Level  B PPE.   The upgrade  of  PPE was  necessary
because of the possible  presence of l,2-dibromo-3-chloropropane.   Personal air
monitoring for  1,2-dibromo-3-chloropropane was conducted during  test pitting
using Gillian™ model HFS 113A pumps with low flow adapters and petroleum-based
charcoal tubes.   All test pit workers  were on supplied  air.  In the breathing
zone of test pit workers, atmospheric concentrations ranging from 1 to 4 parts
per billion (ppb) of l,2-dibromo-3-chloropropane were detected, which is above
the permissible exposure limit (PEL) of 1 ppb.

The geophysical  survey  indicated  19 anomalies in the area  of Site 11.   These
areas are shown on Figure 2-3.  Test pits were excavated  at  these locations to
verify the presence  of pesticide containers.  Pesticide containers were found in
Anomalies 4, 5,  7, 8, and 16.  All  other anomalies contained either nothing or
non-hazardous debris. The results of the product and soil  sampling are provided
in Table 2-1.  Pesticides were found in  three of the six product samples.  Pesti-
cides and metals were found in the soil sample from Anomaly 4. Despite extending
the investigation beyond the  originally designated site,  the  reported deposit of
200 to 450 containers was not found. A total of 41  empty containers,  7 full or

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                       \    r           \\
                               FORMER BORROW\   \
                                                                          ANOMALY 18
                                                                            300  FEET
                                                                LEGEND

                                                                     Monitoring well location
                                                                fj i   Areas of anomaly
                                                                     Dense trees and  underbrush

                                                               	Approximate limits of
                                                                     site clearing and
                                                                     geophysical explorations
                                                                                  50
                                                                                         100
                                                                           SCALE: 1" =  100'
  FIGURE 2-3
  LOCATIONS OF ANOMALIES TEST PITTED
  DURING FOCUSED REMEDIAL INVESTIGATION
CECIL\SURVEY\,MAH-WOW\ 08-24-93
                 INTERIM RECORD OF DECISION
                 SITE 11
                                                                NAS CECIL FIELD
                                                                JACKSONVILLE, FLORIDA
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Table 2-1
Results of Product and Soil Analyses for
Focused Remedial Investigation
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Reid, Jacksonville, Rorida
Sample Compound Detected Type
Product No. 1 alpha-BHC' Pesticide
gamma-BHC Pesticide
2,4-D2 Pesticide
Product No. 5 1,2-Dibromo-3-chloropropane3 Pesticide
Toxaphene Pesticide
Product No. 6 1 ,2-Dibromo-3-chloropropane3 Pesticide
Soil No. 1 1,2-Dibromo-3-chloropropane3 Pesticide
Parathion Pesticide
Aluminum Metal
Arsenic Metal
Barium Metal
Chromium Metal
Copper ' Metal
Iron Metal
Magnesium Metal
Zinc Metal
1 Benzene hexachloride.
2 Dichlorophenoxyacetic acid.
3 Trade name Nemagon».
Notes: Samples collected from containers are referred to as product.
There was no product No. 4 sample collected or analyzed.
Soil No. 1 was collected from Anomaly 4.
No hazardous substances were detected for products No. 2, 3, and 7.
mg/kg = milligrams per kilogram.
fjg/t = micrograms per liter.
pg/kg = micrograms per kilogram.






Concentrations
0.085 mg/kg
0.60 mg/kg
47 mg/kg
680 fjg/t
73fjg/t
340,000 ijg/l
160pg/kg
330pg/kg
1,690 mg/kg
46.6 mg/kg
3.4 mg/kg
4.6 mg/kg
1.2 mg/kg
623 mg/kg
5.0 mg/kg
6.0 mg/kg










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partially full containers, and 3 50-pound bags of powder were found during the
investigation. All full, partially full,  and leaking containers were placed into
overpack drums.   A variety of nonhazardous debris  including pipes,  concrete,
tires, scrap metal, and bottles were encountered during test pitting.


2.4  HIGHLIGHTS OF  COMMUNITY  PARTICIPATION.   The  FFS report and Proposed Plan
were completed and released to the public in February 1994.  A public meeting was
held on March 8,  1994, to present information on the proposed interim remedial
action at  Site 11  and to solicit  comments on the  proposed cleanup.   These
documents and other Installation Restoration program information are available
for public review in the  Information Repository and Administrative  Record.  The
repository  is maintained  at the  Charles  D.  Webb Wesconnett  Branch  of  the
Jacksonville Public Library in Jacksonville, Florida.  The notice of availability
of these  documents was published in The Florida Times Union on February 27, 1994,
and March 6, 1994.

A 30-day public comment period was  held  from  March  2,  1994, to April 1, 1994.
At the public meeting  on March  8,  1994,  representatives from NAS Cecil Field,
USEPA, FDEP, and the Navy's environmental consultants presented information on
the remedial alternatives and answered questions regarding  the proposed interim
remedial action at Site 11.  No written comments were  received during the public
comment period; however, questions asked during the public meeting are summarized
and addressed in Appendix A,  Responsiveness Summary.


2.5  SCOPE  AND  ROLE OF  INTERIM REMEDIAL ACTION.   Investigations at  Site  11
indicated that pesticide containers were deposited in several locations within
the site.  The purpose of this interim remedial action is to remove the source
of contamination to soil  and  groundwater  at Site 11; namely,  the debris and the
contaminated soil encountered during removal of the pesticide containers at the
site.   Based  on  previous investigations and the evaluation of ARARs for this
site,  the following remedial action objectives were identified:

     •  reduce migration and  volatilization of pesticide  contaminants  to  the
        surrounding  environment at  the  site  by  removing  pesticide  wastes,
        containers, and associated obviously contaminated soil; and

     •  characterize wastes removed from the site.

Upon completion  of the overall  Remedial Investigation and Feasibility Study
(RI/FS) for Site  11,  the need for remedial action to address soil or groundwater
contamination will  be  evaluated.   This  IROD  addresses  interim source control
(i.e., removal of pesticide containers) remedial actions only.   It is believed
that this interim action  is consistent with any future remedial activities that
may take place at the site.


2.6  SITE  CHARACTERISTICS.    The geophysical  surveys  and test pitting  have
characterized approximately 2.5 acres at  Site  11 to a depth  of approximately 10
feet below land surface (bis).  The  reported deposit of  200  to 450 buried empty
pesticide containers was not located during this investigation.  The geophysical
survey and test  pits  have  identified  five  anomalies  where  containers  with
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pesticides were found buried and another six anomalies where miscellaneous debris
was  located.    A  total of  41  empty  containers,  7 full or  partially  full
containers, and 3 bags were found during this investigation.

The volume of soil and the number of pesticide containers  that require removal
from Site 11 are developed from the descriptions of materials encountered during
test pitting of magnetic anomalies.  The volume of soil to be excavated for this
remedial action was based on a maximum expected excavation depth of 5 feet bis
at Anomaly 4 and 2 feet  bis at  Anomalies  5,  7,  8,  and 16  (Figure 2-3).   It is
assumed that soil  from anomalies where pesticide containers  were found would
require excavation during the  interim remedial  action.  This includes Anomalies
4, 5, 7,  8,  and  16.  The depth  of excavation was based on the extent of disturbed
soils identified during the Focused RI.  Based on these assumptions, a maximum
of  360  cubic yards  (yd3),  including  a  10 percent  bulking  factor,  would be
excavated from the site during the interim remedial action.

The number of full, partially full,  or leaking pesticide containers to be removed
from the site was estimated based on observations made by field personnel during
the Focused RI.  Anomaly 4 contains an estimated 190 pounds of empty pesticide
containers  and  one 50-pound  bag of powder  requiring removal  from the  site.
Approximately 360 pounds of empty pesticide containers and one  full 50-pound bag
of solid material require removal from Anomalies 5, 7, 8, and 16 and the surface.


2.7  SUMMARY OF SITE RISKS.   The insecticide Nemagon™ contains l,2-dibromo-3-
chloropropane,  which is  the contaminant of concern at Site 11.   This compound has
an Occupational Safety and Health Administration (OSHA)  PEL of 1 ppb, cannot be
detected adequately  by  any  real-time monitoring  instrumentation,  is absorbed
through all routes of entry into the body (inhalation,  ingestion, dermal,  and
eye), can cause breakthrough  in impermeable  work clothing, and causes cancer,
atrophy of the  testicles in men, changes  in  the estrous cycle in women,  liver
disease, kidney disease, skin disease,  and blood disorders.

The purpose of  this  interim remedial action  is to  remove pesticide wastes and
debris,  which are currently  acting  as sources of soil contamination  at Site 11.
A baseline  risk assessment  has  not  been completed at  this  time.    Once  the
overall RI has been  completed,  the baseline  risk assessment  will be completed
using RI data and any risks associated with exposure to contaminated soils and/or
groundwater at Site 11 will  be addressed in a subsequent FS.

Results of the  Focused RI indicated that pesticide containers  were deposited in
several locations within the site.  The results of the sampling and analyses are
presented  in  Table  2-1 (Subsection 2.2.2).    In  sufficient quantity,  these
compounds represent a potential human health and environmental risk if contacted,
ingested, or allowed to migrate freely in surface water,  soil,  sediment, air, or
groundwater.  Removal and appropriate management of wastes and containers with
residues of these compounds  will reduce the risk posed to human health and the
environment.
2.8  DESCRIPTIONS OF  ALTERNATIVES.   Table  2-2  presents a  description of the
source control alternatives evaluated for Site 11.  The alternatives are numbered
to correspond with the alternatives provided in the FFS report (available at the
Information Repository).


CF_S11_I.ROD
MVL08.94                                 2-8

-------

                                                                                        Table 2-2
                                                      Alternatives Evaluated for the Interim Remedial Action at Site 11
                                                                                 Interim Record of Decision
                                                                      Golf Course Pesticide Disposal Area, Site 11, OU 6
                                                                            MAS Cecil Reid, Jacksonville, Rorida
         Alternative
Alternative 1:  Excavation and
offsite Incineration of contami-
nated soil; onsite treatment of
contaminated debris with offsite
disposal of treated debris.
Alternative 2: Excavation and
offsite incineration of contami-
nated soil; offsite treatment
and disposal of contaminated
debris.
Alternative 3:  Excavation
and offsite disposal of con-
taminated soil; onsite treat-
ment of contaminated de-
bris with offsite disposal of
treated debris.
Alternative 4:  Excavation
and offsite disposal of con-
taminated soil, and offsite
treatment and disposal of
debris.
Alternative 6:  Excavation
and offsite disposal of
contaminated soil and
debris.
           Total Cost
           $1,772,000
         $1,770,000
         $708,000
         $705,000
        $749,000
         Sol
    Transport contaminated soil
    to offsite Incinerator.
    Transport contaminated
    soil to offsite Incinerator.
    Transport contaminat-
    ed soil to an offsite
    hazardous waste land-
    fill.
    Transport contaminated
    soil to an offsite hazard-
    ous waste landfill.
    Transport contaminat-
    ed soil to an offsite
    hazardous waste land-
    fill.
         Debris
ro
cb
    Treat contaminated debris
    onsite using high-pressure
    water washing.
    Transport treated debris off-
    site for disposal in  a solid
    waste landfill.
    Transport contaminated
    debris to an offsite
    hazardous waste
    treatment facility for treat-
    ment and disposal.
    Treat contaminated
    debris onsite.
    Transport treated
    debris to offsite solid
    waste landfill.
    Transport contaminated
    debris to offsite hazard-
    ous waste treatment
    facility for treatment
    and disposal.
    Transport contaminat-
    ed debris to an offsite
    hazardous waste land-
    fill.
         Activities
         common to all
         alternatives
1.  Clear and prepare the site.                                       4.
2.  Excavate contaminated debris, Including full, partially full, and      5.
    leaking containers.                                              6.
3.  Stage all pesticide containers; sample contents of partially full      7.
    and leaking containers.                                          8.
                                    Excavate contaminated soil.
                                    Sample excavated soil.
                                    Transport full, partially full, and leaking containers to offsite incinerator.
                                    Backfill excavated areas with native soil.
                                    Demobilize and restore site to its previous condition.

-------
All alternatives  involve excavation  of contaminated debris,  including full,
partially full,  and leaking pesticide containers.  Additionally,  all alternatives
include excavation,  transport, and disposal of up to 360 yd3 of contaminated soil
and transport,  thermal treatment,   and  disposal of full,  partially  full,  and
leaking pesticide containers.   All alternatives involve disposal of both soil
and debris in either hazardous waste or solid waste landfills.

Four alternatives were developed to consider whether  debris should be treated
onsite or offsite and whether contaminated soil should be disposed in a hazardous
waste landfill or incinerated prior  to disposal.  The fifth alternative assumed
all soil and untreated debris would  be placed in a hazardous waste landfill and
would require a variance for landfilling of untreated debris.

Evaluation of a no action alternative,  typically required in a Feasibility Study,
is not necessary in an FFS because designation  of an  interim  remedial action
implies that some action should be  taken.


2.9  SUMMARY OF COMPARATIVE  ANALYSES  OF ALTERNATIVES.   This section evaluates
and compares each of the  alternatives  with respect to the nine criteria used to
assess remedial alternatives as outlined  in  Section 300.430(e)  of  the NCP.   A
comparative  analysis  of  source control  remedial  alternatives  for  the  nine
criteria is provided in Table 2-3.

2.9.1   Overall Protection All alternatives would provide an increased level of
protection of human health and the  environment.   Risks are reduced by removing
pesticides, pesticide containers,  and contaminated soil from the site, thereby
preventing exposure  and  reducing a source of soil and  potential  groundwater
contamination.

2.9.2   Compliance with  Applicable  or  Relevant and Appropriate Requirements
(ARARs).  All alternatives meet  ARARs  with one possible exception.  Alternative
5 can be implemented only if  a Subtitle  C  landfill capacity regulatory variance
extension  is  granted (and the  landfill agrees   to accept  untreated hazardous
debris because capacity is available).  No chemical-specific or location-specific
ARARs were identified for this interim remedial action.  A complete listing of
action-specific ARARs is listed in Table 2-4.

2.9.3   Long-term Effectiveness  and  Permanence The reduction of risk at Site 11
is permanent  for  all alternatives  because pesticide  containers, contaminated
soil,  and debris would be removed from the site.  Constituents remaining after
soil and debris excavation would not pose a direct-contact hazard and would be
addressed during future soil  and groundwater  remediation if they are determined
to pose a risk.

2.9.4   Reduction  of  Toxicity.  Mobility,  or  Volume  of  the  Contaminants
Alternatives 1, 2, and 4  would  achieve  significant  and permanent reduction in
toxicity, mobility,  and volume of product and  contaminants on debris  and in soil.
Alternative 3 would  result in a significant and permanent reduction of toxicity,
mobility, and volume of contaminants on  debris;   the toxicity of  soil would not
be reduced because contaminated  soil would be transported offsite  to a hazardous
waste  landfill.   Alternative  4 would  reduce  the  mobility  and volume  of
contaminants of soil and debris onsite,  but would not reduce the toxicity of
CF S11J.ROD
MvLoa.94                                2-10

-------
$':-
ro


Table
Comparative Analyses of Source


Interim Record
2-3
Control Remedial Alternatives
of Decision



Golf Course Pesticide Disposal Area, Site 11, OU 6
MAS Cecil Reid, Jacksonville, Rorida
Criterion
Overall Protection of Human
How risks are eliminated,
reduced, or controlled








Short-term or cross-media
effects





Compliance with ARARs
Chemical-, location-, and
action-specific ARARs




Alternative RA-1
Health and the Environment
Alternative RA-1 would
provide an increased level of
protection to human health
and the environment because
risks via direct contact with or
inhalation of pesticide con-
taminants at the site are
minimized. Worker health
and safety requirements
would be maintained.
No short-term adverse effects
are expected to occur during
implementation of this alter-'
native. Care will be taken to
prevent cross-media con-
tamination during remedial
action.

Would comply.





Alternative RA-2

Analysis is the same as
for Alternative RA-1.








Analysis is the same as
for Alternative RA-1.






Analysis is the same as
for Alternative RA-1.




Alternative RA-3 Alternative RA-4

Analysis is the same as Analysis Is the same as
for Alternative RA-1. Soil for Alternative RA-1. Soil
would not be treated would not be treated prior
prior to disposal. to disposal.






Analysis is the same as Analysis is the same as
for Alternative RA-1. for Alternative RA-1.






If concentrations of pes- Analysis is the same as
ticide contaminants in for Alternative RA-3.
sol) do not meet the land
ban criteria, this alter-
native would not meet
ARARs.
Alternative RA-5

Analysis is the same as
or less than that for
Alternative RA-1.
Neither soil nor debris
would be treated prior
to disposal.




Analysis is the same as
for Alternative RA-1.






If concentrations of pes-
ticide contaminants in
soil and on debris do
not meet the land ban
criteria, this alternative
would not meet ARARs.
See notes at end of table.

-------
2°

s
8'r-
ro
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Field, Jacksonville, Rorida
Criterion
Alternative RA-1
Alternative RA-2
Alternative RA-3
Alternative RA-4
Alternative RA-5
Long-term Effectiveness and Permanence
Magnitude of
residual risk










Adequacy of
controls

Reliability of controls




Reduction of Mobiity,
Treatment process
and remedy






Amount of
hazardous material
destroyed or treated


The reduction in risk at Site 1 1
would be permanent because pes-
ticide containers would be removed
from the site. Other contaminated
media at the site remaining after
implementation of the remedial
action would be addressed in the
overall FS for Site 11. Risk as-
sociated with hazardous
constituents in soil and on debris Is
reduced through treatment or
destruction of these constituents.
Implementation of alternative would
provide immediate and long-term
source control at Site 11.
Incineration is highly reliable. High
pressure washing is reliable as long
as wash water is contained.


Toxicity, and Volume
Contaminated nonporous debris
would be treated via high pressure
washing. Generated water would
also be treated. Soil would be
treated via incineration.



Approximately 550 pounds of
empty and 165 pounds of full
pesticide containers and 360 yd3 of
soil would be treated for this
alternative.
Analysis is the same as
for Alternative RA-1.










Analysis is the same as
for Alternative RA-1.

Analysis is the same as
for Alternative RA-1.




Analysis is the same as
for Alternative RA-1.






Analysis is the same as
for Alternative RA-1.



Analysis is the same as
for Alternative RA-1;
however, the
Implementation of this
alternative is less
favorable than Alternative
RA-1 because no
treatment of
contaminated soil is
employed.


Analysis is the same as
for Alternative RA-1.

Landfilling of wastes is
reliable. High pressure
washing is reliable as
long as wash water is
contained.

Contaminated debris
would be treated via
high pressure washing.
Generated water would
also be treated. No
treatment processes
would be implemented
for contaminated soil.
550 pounds of empty
and 165 pounds of full
pesticide containers
would be treated for this
alternative.
Analysis is the same as
for Alternative RA-1;
however, the
implementation of this
alternative is less
favorable than Alternative
RA-1 because no
treatment of
contaminated soil is
employed.


Analysis is the same as
for Alternative RA-1.

Analysis is the same as
for Alternative RA-3.




Analysis is the same as
for Alternative RA-3.






Analysis is the same as
for Alternative RA-3.

•

Analysis is similar to
Alternative RA-1 but
because pesticide
contaminants are not
destroyed, only their
mobility and potential
for exposure to
receptors will be
reduced, the reduction
is less than Alternative
RA-1.

Analysis is the same as
for Alternative RA-1.

Disposal of soil and
debris is reliable.




No treatment processes
would be employed to
treated contaminated
soil or debris.




This alternative does
not provide for treat-
ment of contaminated
soil or debris.

See notes at end of table.

-------
s °
N)




CO
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Reid, Jacksonville, Rorida
Criterion
Alternative RA-1
Alternative RA-2
Alternative RA-3
Alternative RA-4
Alternative RA-5
Reduction of Moblhy. Toxfcity, and Volume (Continued)
Reduction of
mobility, toxicity,
or volume through
treatment

Irreversibility of
treatment

Type and quantity
of treatment
residuals
Short-term
Effectiveness
Protection of
community during
remedial action
Protection of
workers during
remedial actions

Would achieve significant and permanent
reduction In toxicity, mobility, and volume
of contaminants on debris and in soil.

Incineration and high pressure washing are
irreversible.

Approximately 480 gallons of wash water
would be produced that would require
further treatment and disposal. Ash would
be produced during incineration but would
be managed by the offslte incineration
facility.


Dust control would be required during
excavation of soil. Fact sheets and posters
providing Information to the public
regarding the remedial action would be
distributed. Transportation of wastes offsite
poses a specific level of risk.
Workers would be required to follow an
approved Health and Safety Plan. Workers
within the exclusion zone would be dressed
in Level B protection and would be on a
special medical monitoring program.
Analysis is the same as
for Alternative RA-1.

Analysis Is the same as
for Alternative RA-1.

Wash water and ash
would be produced
during Implementation
of this alternative, but
both residuals would be
managed by the offsite
treatment facility.


Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.

Would achieve significant and
permanent reduction In
toxicity, mobility, and volume
of contaminants on debris.
No reduction in toxicity of
contaminants in soil.
High pressure washing of
debris is irreversible.

Approximately 480 gallons of
wash water would be
produced that would require
further treatment and
disposal.


Analysis is the same as for
Alternative RA-1.
Analysis is the same as for
Alternative RA-1.

Analysis is the same
as for Alternative
RA-3.

Analysis is the same
as for Alternative
RA-3.
Wash water would be
produced during
Implementation of
this alternative, but
would be managed
by the offsite
treatment facility.


Analysis is the same
as for Alternative
RA-1.
Analysis is the same
as for Alternative RA-
1.

No reduction in the
toxicity of
contaminants on
debris or in soil.

Not applicable.

No treatment
residuals would be
produced if this
alternative were
implemented.


Analysis is the
same as for
Alternative RA-1.
Analysis is the
same as for
Alternative RA-1.

See notes at end of table.

-------
&
ro
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11. OU 6
MAS Cecil Reid. Jacksonville, Florida
Criterion
Alternative RA-1
Alternative RA-2
Alternative RA-3
Alternative RA-4
Alternative RA-5
Short-term Effectiveness (Continued) '
Environmental effects

Time until remedial
action objectives are
achieved
Implementablity
Ability to construct
technology
Reliability of
technology

Ease of undertaking
additional remedial
action, if necessary
Monitoring
considerations
No effects to surrounding environment
expected. Releases to air are expected to
have minimal environmental effect based
on the results of the dust monitoring
conducted during the Focused Rl.
Approximately 5 weeks are necessary to
meet the remedial action objectives for
Site 11.

High pressure washer would be delivered
prefabricated to the site.
Treatment standards for contaminated
debris and soil would be achieved via high
pressure washing and Incineration,
respectively.

Would provide no Impediment to additional
remediation.

Air monitoring would be conducted as
appropriate during excavation,
transportation, and debris treatment.
Medical monitoring of workers within the
exclusion zone would be required.
Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.

No construction
necessary.
Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1,
Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.

High pressure washer
would be delivered
prefabricated to the
site.
Treatment standards
for contaminated
debris would be
achieved via high
pressure washing.
Regulated landfills are
designed and
constructed to
minimize leaching of
contaminants.
Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.

No construction
necessary.
Analysis is the same
as for Alternative RA-3.

Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.

No technology
construction
necessary.
Regulated landfills are
designed and
constructed to
minimize leaching of
contaminants.

Analysis is the same
as for Alternative RA-1.

Analysis is the same
as for Alternative RA-1.
See notes at end of table.

-------
fc'r-
fji
_A
Ol
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Field, Jacksonville, Florida
Criterion Alternative RA-1
Implementabiity (Continued)
Coordination with other Coordination with NAS Cecil Field
regulatory agencies personnel required for duration of
remedial activities. Coordination with
county, USEPA, FDEP, and TSD for
incinerator necessary.
Availability and capacity Availability of permitted TSD facilities
of treatment, storage, for treatment of contaminated soil
and disposal services would be required at the time of
remedial action. Vendors that provide
equipment necessary for high
pressure washing are available.
Availability of tech- Construction contractors, equipment,
nofogies, equipment, and and laboratories are available.
specialists
Ability to obtain Approval from State and USEPA
approvals from other necessary prior to offsite treatment of
agencies contaminated soil.
Cost
Capital Costs $1,541,000
Total present worth $1,772,000
(including contingency)
Notes: TSD = treatment, storage, and disposal.
NAS = Naval Air Station.
ARAB = applicable or relevant and appropriate requirements.
FS = feasibility study.
Alternative RA-2 Alternative RA-3

Analysis is the Analysis Is the same as for
same as for Alternative RA-1.
Alternative RA-1.
Less coordination
necessary than for
onsite treatment
of debris.
Analysis is the Availability of landfills
same as for permitted to accept excavated
Alternative RA-1. soil would be required at the
time of remedial action. Ven-
dors that provide equipment
necessary for high pressure
washing are available.
Analysis is the Analysis is the same as for
same as for Alternative RA-1.
Alternative RA-1.
Analysis is the Approval from State and
same as for USEPA necessary prior to
Alternative RA-1. offsite disposal of con-
taminated soil.

$1,539,000 $615,000
$1,770,000 $708,000
Alternative RA-4

Analysis is the
same as for
Alternative RA-1.
Less coordination
necessary than
for onsite
treatment of
debris.
Analysis is the
same as for
Alternative RA-3.
Analysis is the
same as for
Alternative RA-1.
Analysis is the
same as for
Alternative RA-3.

$613,000
$705,000
Alternative RA-5

Analysis is the same as
for Alternative RA-1.
Availability of landfills
permitted to accept ex-
cavated soil and debris
would be required at
the time of remedial
action.
Analysis is the same as
for Alternative RA-1.
Approval from State
and USEPA necessary
prior to offsite disposal
of contaminated soil
and debris.

$651,000
$749,000
yd3 = cubic yard.
Rl = remedial investigation.
USEPA = U.S. Environmental Protection Agency.
FDEP = Rorida Department of Environmental Protection.

-------
                                                                                 Table 2-4
                                                  Synopsis of Potential Federal and State Action-Specific ARARs

                                                                          Interim Record or Decision
                                                                Golf Course Pesticide Disposal Area, Site 11, OU 6
                                                                      NAS Cecil Field, Jacksonville, Florida
          Federal and State Stan-
         dards and Requirements
        Requirements Synopsis
 Applicable or Relevant and Appropriate
   Consideration In the Remedial Response Process
ro
o>
         Clean Air Act (CAA), Na-
         tional Ambient Air Quality
         Standards (NAAQS) (40
         Code of Federal Regula-
         tions [CFR] Part 50)
         CAA, New Source Perfor-
         mance Standards (NSPS)
         (40 CFR Part 60)
         Resource Conservation
         and Recovery Act
         (RCRA), Standards for
         Owners and Operators of
         Hazardous Waste Treat-
         ment, Storage, and
         Disposal Facilities (TSDF)
         (40 CFR Part 264)
Establishes primary  (health-based)  and
secondary (welfare-based) standards for air
quality for carbon monoxide, lead, nitrogen
dioxide,  particulate matter, ozone,  and
sulfur oxides.
This regulation  establishes  NSPS for
specified sources, including incinerators.
This rule establishes a particulate emission
standard of 0.08 grains per dry standard
cubic foot corrected to 12 percent carbon
dioxide for sources.
This rule establishes minimum national
standards that  define  the  acceptable
management of hazardous  wastes for
owners and operators of facilities that treat,
store, or dispose of hazardous wastes.
Relevant and Appropriate. This rule is not
strictly applicable because the source of
contamination (i.e., dust from excavation)
is not a "major source" based on volume of
release of the regulated contaminant.
Applicable. The new source performance
standards must be met by the incinerator
employed for offslte treatment.
Applicable. The minimum standards must
be met for treatment of hazardous debris
on site.
Relevant  and  Appropriate.   Minimum
standards must be met for treatment of
debris contaminated with material which is
significantly similar to a hazardous waste.
Site remedial activities must comply with NAAQS.  The
most relevant pollutant standard is for particulate matter
less than 10 microns in size (PM,0) as defined in 40 CFR
Section 50.6.  The PM,0 standard is based on the detri-
mental effects of particulate matter to the lungs of hu-
mans.  The PM10 standard for a 24-hour period is 150
micrograms per cubic meter (/t/g/m3) of air, not to be
exceeded  more  than  once  a  year.   Remedial con-
struction  activities  such as  excavation will  need to
include controls to ensure compliance with the PM,0
standard.  The attainment and maintenance of primary
and secondary NAAQS are required to protect human
health  and  welfare   (wildlife,   climate,   recreation,
transportation, and economic values).  These standards
are applicable during remedial activities, such as soil
excavation, that may result in exposure to hazardous
chemicals through dust and vapors.

Because NSPS are source-specific requirements, they
are  not   generally   considered   applicable   to
Comprehensive   Environmental   Response,
Compensation,  and Liability Act  (CERCLA)  cleanup
actions. However, an NSPS  may be applicable for an
incinerator; or may be  a relevant and appropriate re-
quirement If the pollutant emitted and the technology
employed  during the  cleanup action are  sufficiently
similar to the pollutant and source category regulated.

If  a  remedial alternative  for  Site  11 involves  the
management of RCRA  wastes at an offsite treatment,
storage, or disposal unit, the substantive requirements
of this  rule would be an applicable or relevant and ap-
propriate requirement (ARAR).

-------
                                                                          Table 2-4 (Continued)
                                                  Synopsis of Potential Federal and State Action-Specific ARARs
                                                                           Interim Record of Decision
                                                                Golf Course Pesticide Disposal Area, Site 11, OU 6
                                                                      NAS Cecil Reid, Jacksonville, Florida
             Federal and State
              Standards and
              Requirements
         Requirements Synopsis
Applicable or Relevant and Appropriate      Consideration in the Remedial Response Process
ro
         RCRA, Use and
         Management of
         Containers (40 CFR Part
         264, Subpart I)
         RCRA, Incinerators (40
         CFR Subpart O, 264.340-
         264.599)
         RCRA, Manifest System,
         Recordkeeping, and
         Reporting (40 CFR Part
         264, Subpart E)
         Hazardous Materials
         Transportation Act (49
         CFR Parts 171, 173, 178,
         and 179) and Hazardous
         Materials Transportation
         Regulations

         RCRA, Standards
         Applicable to
         Transporters of
         Hazardous Waste (40
         CFR Part 263, Subparts
         A -C, 263.10-263.31)
Sets standards for the storage of containers
of hazardous waste.
This regulation specifies the performance
standards, operating requirements, and moni-
toring, inspection, and closure guidelines for
any  incinerator  that manages hazardous
waste.

This rule outlines procedures for manifesting
hazardous waste for owners and operators of
onsite and offsite facilities that treat, store, or
dispose of hazardous waste.


These regulations outline procedures for the
packaging,   labeling,   manifesting,   and
transporting of hazardous materials.
This  rule   establishes   procedures   for
transporters of hazardous  waste within the
United States if the transportation requires a
manifest under 40 CFR Part 262.
Applicable. If waste Is hazardous, these
requirements must be met for storage of
waste in containers.
Relevant and Appropriate. If waste is
significantly  similar  to a hazardous
waste, storage in containers must meet
these requirements.

Applicable.   Offsite incinerator must
meet these requirements for treatment
of hazardous wastes.
Applicable. If waste is hazardous, these
requirements   must  be   met  for
transportation of waste offsite.
Applicable. If waste is hazardous, these
requirements   must  be   met  for
transportation   of   hazardous   waste
offsite.
Applicable.  If waste to be transported
offsite is hazardous, these requirements
must be met.
Any  remedial  action implemented at Site  11  would
involve the storage  of containers of RCRA hazardous
waste. The staging of study-generated RCRA wastes
should meet the intent of this regulation.  These require-
ments are relevant  and appropriate for containerized
wastes at CERCLA sites.
These requirements are applicable for remedial actions
involving the  offsite incineration  of RCRA-regulated
wastes.
These  regulations apply  if  a  remedial  alternative
involves the offsite treatment, storage, or disposal of
hazardous waste.  For remedial actions Involving onsite
treatment or disposal of hazardous waste, these regula-
tions are applicable.

For remedial actions involving offsite treatment, storage,
or disposal, contaminated media materials would need
to be  packaged, manifested, and transported to  a
licensed offsite facility in compliance  with these regu-
lations.
If a remedial alternative involves offsite transportation of
hazardous waste for treatment, storage, or disposal,
these requirements must be attained.

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                                                                          Table 2-4 (Continued)
                                                   Synopsis of Potential Federal and State Action-Specific ARARs

                                                                           Interim Record of Decision
                                                                Golf Course Pesticide Disposal Area, Site 11, OU 6
                                                                       NAS Cecil Reid, Jacksonville, Rorida
           Federal and State
            Standards and
            Requirements
            Requirements Synopsis
Applicable or Relevant and Appropriate      Consideration In the Remedial Response Process
r\i
oo
         RCRA, Standards
         Applicable to
         Generators of
         Hazardous Waste
         (40 CFR Part 262,
         Subparts A - D,
         262.10-262.44)

         RCRA, Hazardous
         Waste Management
         System
         (40 CFR Part 260)
         RCRA, Identification
         and Listing of
         Hazardous Waste
         (40 CFR Part 261,
         261.1-261.33)
These rules establish standards for generators of
hazardous wastes that  address:   accumulating
waste,  preparing  hazardous waste for shipment,
and  preparing  the  uniform  hazardous  waste
manifest.  These requirements are integrated with
U.S.    Department   of   Transportation   (DOT)
regulations.

Sets forth procedures that the U.S. Environmental
Protection Agency  (USEPA)  will use  to  make
information available to the public and sets forth
rules that TSDFs  must follow to assert claims of
business confidentiality with respect to information
submitted to the USEPA pursuant to 40 CFR Parts
261-265.

This rule defines those solid wastes that are subject
to regulation as hazardous wastes under 40  CFR
Parts  262-265.    The   applicability  of  RCRA
regulations to wastes found at a site is dependent
on the solid waste meeting  one of the following
criteria: (1) the wastes are generated through a
RCRA  listed source process, (2)  the wastes are
RCRA-listed wastes from a non-specific source, or
(3) the  waste is characteristically hazardous due to
ignitability, corrositivlty, reactivity, or toxicity.
Applicable.  If waste to be disposed of
offsite is hazardous, these requirements
must be met.
Applicable.  Where  wastes  disposed
offsite are hazardous, the requirements
of this rule must be met.
Applicable.  The criteria for identifying
wastes, as defined by this rule, must be
met.
If an alternative involves the offsite transportation of
hazardous wastes, the material  must be shipped in
proper containers  that are accurately  marked  and
labeled,  and the  transporter must display proper
placards. These rules specify that all hazardous waste
shipments must be accompanied by an appropriate
manifest.

Whereas this regulation does not stipulate substantive
cleanup requirements, it details confidentially proce-
dures for offsite TSDFs.
Full pesticide containers removed from Site 11 may be
classified as RCRA wastes.  If a container is labeled,
the chemical constituents of  the container may be
identified from respective Material Safety Data Sheets
(MSDS).  If a container is not labeled, the contents of
the container will be analyzed for RCRA characteristics
that  include  pesticides (including  1,2-dibromo-3-
chloropropane) suspected to be disposed at the site.
Excavated soil will be analyzed to identify any hazard-
ous constituents contained in the soil.  All soils and
containers will be managed in accordance with this
regulation. Residuals from the treatment of hazardous
debris (e.g., decontamination water) may be classified
as RCRA hazardous waste. Treatment residuals will be
sampled,  analyzed,  and  disposed based  on the
analytical results.

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                                                                          Table 2-4 (Continued)
                                                  Synopsis of Potential Federal and State Action-Specific ARARs

                                                                          Interim Record of Decision
                                                                Golf Course Pesticide Disposal Area, Site 11, OU 6
                                                                      MAS Cecil Field, Jacksonville, Rorida
          Federal and State
            Standards and
            Requirements
              Requirements Synopsis
    Applicable or Relevant and
           Appropriate
 Consideration in the Remedial Response Process
N>

CO
         RCRA, Land
         Disposal Restrictions
         for Newly Usted
         Wastes and
         Hazardous Debris
         (40 CFR Parts 148,
         260, 261, 262, 264,
         265, 270, and 271)
         RCRA, Corrective
         Action Management
         Units; Corrective
         Action Provisions
         Under Subtitle C (40
         CFR Parts 260, 264,
         265, 268, 270, and
         271)

         RCRA, Land
         Disposal Regula-
         tions (LDRs) (40
         CFR Part 268)
This rule sets forth five options for management of
hazardous debris: (1) treat the debris to performance
standards established in this  rule through one of 17
approved technologies, (2) obtain a ruling from USEPA
that the debris no longer contains hazardous waste, (3)
treat the debris using a technology approved through an
"equivalent technology demonstration,* (4) treat the
debris  to existing Land  Disposal Restriction  (LDR)
standards for wastes contaminating  the  debris  and
continue  to  manage under RCRA Subtitle C,  or (5)
dispose of debris  in a Subtitle C landfill under the
generic extension of the capacity variance for hazardous
debris, which currently expires on May 8, 1994.
This rule establishes corrective action management units
(CAMU) and temporary units (TUs)  as two options for
corrective actions at permitted RCRA facilities.
This rule establishes restrictions for the land disposal of
untreated  hazardous  wastes and  provides treatment
standards for these land-banned wastes.  Under this
rule, treatment  standards have been established  for
most listed hazardous wastes.
Applicable. This rule is applicable for
treatment of hazardous debris onsite.
Relevant and Appropriate.   These
requirements must be met for onsite
treatment of debris contaminated with
waste that  is significantly similar to
hazardous waste.
Applicable. Storage and treatment of
hazardous wastes onsite would  be
subject to these requirements.
Relevant and Appropriate.  Storage
and  treatment  of wastes that are
determined to be significantly similar
to  hazardous  wastes  would  be
subject to these requirements.

Applicable.     If  the   waste  is
characterized as a RCRA hazardous
waste, the RCRA-contaminated sub-
stance is to be "placed" (i.e., moved
from the site to a landfill),  and the
waste is to be land disposed,  LDRs
would apply.
Relevant and Appropriate. The land
disposal restrictions must be met if
the waste is significantly similar to the
RCRA-hazardous waste.
Debris at Site 11 (i.e., empty pesticides containers)
would  be classified  as hazardous debris if  it is
contaminated with RCRA listed waste that has LDR
standards or  with  waste  that  exhibits  a  toxic
characteristic.  Under CERCLA, removal of contami-
nants from debris by decontamination and replacing
the debris within an area of concern  (AOC) is per-
mitted. As long as movement of waste is conducted
within the AOC and outside of a separate RCRA unit,
placement  of  wastes  have  not  occurred   and,
therefore, LDRs are not  triggered.  However,  if the
debris  is determined to be hazardous, and place-
ment is determined to occur,  one of the five  listed
options must be selected  for management of the
hazardous debris.

The  substantive requirements of  this  rule   is a
potential ARAR at Site 11 because hazardous wastes
would be stored onsite for any remedial  alternative
implemented.
Treatment standards for wastes removed at Site  11
would be established upon completion of testing of
materials.  If it is determined that wastes removed
from Site 11 are subject to these regulations, then
the wastes must be treated prior to disposal in a
RCRA Subtitle C landfill.

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fc'r-
                                                                 Table 2-4 (Continued)
                                         Synopsis of Potential Federal and State Action-Specific ARARs

                                                                 Interim Record of Decision
                                                       Golf Course Pesticide Disposal Area, Site 11, OU 6
                                                             NAS Cecil Reid, Jacksonville, Rorida
          Federal and State
            Standards and
            Requirements
                                Requirements Synopsis
   Applicable or Relevant and Appropriate
Consideration in the Remedial Response Process
N»
RCRA. Contingency
Plan and
Emergency
Procedures (40 CFR
Subpart D, 264.30-
264.37)


Occupational Safety
and Health Act
(OSHA), General
Industry Standards
(29 CFR Part 1910)


OSHA,
Recordkeeping,
Reporting, and
Related Regulations
(29 CFR Part 1904)


OSHA Health and
Safety Standards
(29 CFR Part 1926)
         RCRA, General
         Facility Standards
         (40 CFR Subpart B,
         264.10-264.18)
                              This regulation outlines  the  requirements for
                              procedures to be followed in the event of an
                              emergency such as an explosion, fire, or other
                              emergency event.
                              This act requires establishment of programs to
                              assure worker health and safety at hazardous
                              waste sites, including employee training require-
                              ments.
                              Provides recordkeeping  and reporting require-
                              ments applicable to remedial activities.
                              Specifies the type of safety training, equipment,
                              and procedures to be used during site investiga-
                              tion and remediation.
                     Sets the general facility requirements including
                     general waste analysis, security measures,  in-
                     spections, and training requirements.
Applicable.  Treatment, storage, and disposal
of hazardous wastes would be subject to these
requirements.
Relevant and Appropriate.  Onsite storage and
treatment of wastes which are determined to be
significantly similar to hazardous wastes would
be subject to these requirements.

Applicable.  OSHA requirements apply to all
site work involving hazardous wastes.
Relevant and Appropriate. OSHA requirements
apply to sites involving work with substances
that  are significantly similar  to hazardous
wastes.

Applicable.  OSHA requirements  apply to all
site work.
Relevant and Appropriate. OSHA requirements
apply to sites involving work with substances
that  are significantly similar  to hazardous
wastes.

Applicable.  OSHA requirements apply to all
site work.
Relevant and Appropriate. OSHA requirements
apply to sites involving work with substances
that  are significantly similar  to hazardous
wastes.

Applicable.  Any offsite TSDF employed to
treat,  store, or  dispose  of hazardous waste
would be subject to these requirements. Stora-
ge and treatment of hazardous wastes onsite
would also be subject to these requirements.
Relevant and  Appropriate.    Storage and
treatment of wastes that are determined to be
significantly similar to hazardous wastes would
be subject to these requirements.
These requirements are relevant and appropriate
for remedial actions involving the management of
hazardous waste.
Under 40 CFR 300.38, requirements apply to all
response activities under  the  National Oil and
Hazardous Substances Pollution Contingency Plan
(NCP).  During remedial action at the site, these
regulations must be maintained.
These requirements apply to all site contractors
and subcontractors and must be followed during
all site work.  During remedial action at the site,
these regulations must be maintained.
All phases of the remedial response project should
be executed In compliance with this regulation.
During remedial action at the site, these regula-
tions must be maintained.
Because the remedial action planned for Site 11
involves the management of RCRA wastes at an
offsite TSDF, these requirements are applicable.

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S
                                                            Table 2-4 (Continued)
                                    Synopsis of Potential Federal and State Action-Specific ARARs

                                                            Interim Record of Decision
                                                  Golf Course Pesticide Disposal Area, Site 11, OU 6
                                                        MAS Cecil Held, Jacksonville, Rorida
                Federal and State
                 Standards and
                 Requirements
                          Requirements Synopsis
                                    Applicable or Relevant and Appropriate
                                                    Consideration in the Remedial Response
                                                                  Process
ro
ro
              RCRA, Preparedness
              and Prevention (40
              CFR Part 264,
              Subpart C)
Chapter 17-736,
Florida Administrative
Code (FAC),
Rorida Rules on
Hazardous Waste
Warning Signs, July
1991
              Federal Insecticide,
              Fungicide, and
              Rodenticide Act
              (FIFRA) (40 CFR Part
              165)


              RCRA, Solid Waste
              Land Disposal
              Requirements (40
              CFR Part 258)
This   regulation   outlines
requirements  for safety  equip-
ment   and   spill-control   for
hazardous  waste   facilities.
Facilities  must be   designed,
maintained,  constructed,  and
operated to minimize the possi-
bility of an unplanned release
that  could   threaten  human
health or the environment.

Requires  warning   signs  at
National Priority Ust (NPL) and
Rorida Department of Environ-
mental   Regulation   (FDEP;
formerly Rorida Department of
Environmental   Regulation
[FDER])  identified  hazardous
waste sites to inform the public
of the  presence  of  potentially
harmful conditions.

Provides   procedures  for   the
storage   and  disposal  of
pesticides,  pesticide  related
wastes, and their containers.
                       This rule sets forth requirements
                       for disposal of waste within  a
                       solid waste landfill.  Also sets
                       forth  construction   and
                       monitoring  requirements   of
                       Subtitle D landfills.
Applicable.  Any offsite TSDF employed to treat,
store, or dispose of hazardous waste would be sub-
ject to these requirements. Storage and treatment
of hazardous wastes onsite would also be subject to
these requirements.
Relevant and Appropriate. Storage and treatment
of wastes which are determined to be significantly
similar to hazardous  wastes  would be subject to
these requirements.


Applicable.  Warning signs must be placed on NPL
sites.
                                                     Applicable.  Specified pesticides must be managed
                                                     according to the requirements established In this
                                                     rule.
                               Applicable.  The requirements established in this
                               rule are applicable to waste determined to be non-
                               hazardous.
                                                                                                     Safety and communication equipment should be
                                                                                                     incorporated  into all  aspects  of  the remedial
                                                                                                     process and local authorities should be familiar-
                                                                                                     ized with site operations.
Because  Naval Air Station (NAS) Cecil  Reid is
currently  listed on the NPL, this requirement is
applicable.
                                                FIFRA requirements are action-specific ARARs for
                                                pesticide-contaminated   media.      Remedial
                                                alternatives for Site 11 would include provisions
                                                for drumming, storing, and disposing pesticide
                                                contaminated wastes; FIFRA requirements must
                                                be met.

                                                This  rule  stipulates  that  no free liquids,  no
                                                hazardous wastes, and no reactive wastes may be
                                                deposited within a Subtitle D landfill.

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contaminants in either soil or debris because contaminants would be transferred
to an offsite hazardous waste landfill.

2.9.5   Short-Term  Effectiveness    Dust  control would  be  required  during
excavation of soil.  Volatilization  of the contaminants would be monitored and
controlled during excavation and transport.  Releases to the  air are expected to
have minimal environmental  effect  based  on the results of the dust monitoring
conducted during the Focused RI.

2.9.6   Implementabilitv    It  is  expected  that  all  alternatives  would  be
implementable at  Site  11.   Equipment and  services necessary  for the removal,
treatment, and disposal of  contaminated media at Site 11 are  readily available.

2.9.7   Cost The  range of cost for the two  preferred alternatives (Alternatives
1 and 3) is $1,772,000  to $708,000,  respectively.  A range is provided because
the volume of soils  requiring thermal treatment is  not known at this time but
will be evaluated  during implementation of the interim remedial action. The most
expensive alternative  is Alternative 1  because offsite thermal  treatment  of
contaminated soil  by incineration and onsite treatment of contaminated debris is
costly.

2.9.8   State and  Federal Acceptance  The FDEP and USEPA have concurred with the
Navy's selection of a combination of these alternatives.

2.9.9   Community Acceptance  The  community  has accepted  the selected remedy.
No written comments were received during the public comment period.  In general,
comments  raised during  the public  meeting  on March  8,  1994,  supported the
selected alternatives and the expedient implementation of the interim remedial
action.
2.10 SELECTED REMEDY.  The preferred alternative for source control at Site 11
is a combination of Alternatives 1 and 3.   The combination of these alternatives
would meet the LDR requirements by  transporting  contaminated soil above the LDR
treatment standards offsite for incineration prior  to disposal and transporting
contaminated soil below the LDR standards to a hazardous  waste landfill.  Every
20 yd3 of excavated  soil will be sampled and analyzed to  determine pesticide
contaminant concentrations.   In addition,  contaminated debris  will be treated
onsite using high-pressure water washing  prior to disposal of treated debris in
a solid waste landfill.  A combination of Alternatives  1  and 3 is protective of
the environment, a permanent remedy, and cost effective.

The interim remedial action at Site 11 will be conducted in Level B PPE due to
the possible exposure to l,2-dibromo-3-chloropropane.  The Navy estimates that
the preferred alternative would cost between $708,000 and $1,772,000 and would
take 5 weeks to implement.


2.11 STATUTORY  DETERMINATIONS.   The  interim  remedial action selected  for
implementation at Site 11 is consistent with CERCLA and the NCP.  The selected
remedy is protective of human health and  the environment, attains ARARs, and is
cost effective.  The  selected remedy also satisfies  the  statutory preference for
treatment that permanently and significantly reduces  the  mobility, toxicity, or
volume  of hazardous  substances  as  a principal element.   Additionally,  the

CF_S11_I.ROD
MVLoa.94                                 2-22

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selected  remedy uses  alternate treatment  technologies  or resource  recovery
technologies to the maximum extent practicable.  Any soil contamination remaining
onsite after this interim remedial  action will be addressed during the RI and FS
for this OU and the resulting ROD.


2.12 DOCUMENTATION OF SIGNIFICANT CHANGES.  There are no significant changes in
the interim remedial action from that described in  the  Proposed Plan.
CF_S11 I.ROD
MVL08.94                                 2-23

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                                  REFERENCES
ABB  Environmental Services,  Inc.  (ABB-ES),   1993,  Handbook of  Applicable or
     Relevant and Appropriate Requirements for Navy Sites within the State of
     Florida:   prepared  for  the Department  of the Navy,  Southern Division,
     Charleston,  South Carolina, August 1993.

ABB-ES,  1994a,  Focused Feasibility  Study, Site  11,  Operable Unit  6,  Source
     Control  Remedial Alternatives, NAS  Cecil Field,  Jacksonville,  Florida:
     prepared  for  the  Department  of  the   Navy,  Southern  Division,  North
     Charleston,  South Carolina, January 1994.

ABB-ES,  1994b,  Proposed  Plan for Interim  Remedial  Action,  Naval Air Station,
     Cecil Field, Site 11,  Golf Course Pesticide Disposal Area, Jacksonville,
     Florida:  prepared for the Department of the Navy,  Southern Division, North
     Charleston,  South Carolina, February  1994.

Envirodyne Engineers, 1985, Initial Assessment Study of Naval Air Station Cecil
     Field, Jacksonville, Florida:  prepared  for Naval  Energy and Environmental
     Support  Activity (NEESA), NEESA  13-073,  Port Hueneme,  California,  July
     1985.

Harding Lawson Associates, 1988, RCRA Facility Investigation, NAS Cecil Field,
     Jacksonville, Florida.

USEPA, 1988,  Guidance for Conducting Remedial  Investigations  and Feasibility
     Studies Under CERCLA, Interim Final:  Office of Solid Waste and Emergency
     Response, Washington, DC,  October 1988.

USEPA, 1990a, National Oil and Hazardous  Substances  Pollution Contingency Plan:
     40 CFR Part  300, Washington, DC, March 1990.

USEPA,  1990b,  A  Guide  to Developing  Superfund Records  of Decision,  Quick
     Reference  Fact  Sheet:    Office  of  Emergency   and  Remedial  Response,
     Washington,  D.C., 9335.3-02FS-1, May  1990.

USEPA,  1991,  Guide  to  Developing  Superfund No  Action,  Interim Action,  and
     Contingency  Remedy RODs,  Quick Reference Fact  Sheet:  Office of Emergency
     and Remedial Response, Washington, D.C., 9335.3-02FS-3, April 1991.
CF_S11J.ROD
MVL08.94                                Ref-1

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      APPENDIX A




RESPONSIVENESS SUMMARY

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                                                               Responsiveness Summary

                                                    Site  11 Source Control Remedial Alternatives

                                                                    NAS Cecil Reid, Florida
                Comment
                                                     Response
QUESTIONS FROM THE PUBLIC MEETING

Why did you choose onslte treatment of
debris versus offsite?
Did you look at the groundwater or just at
the soil at this time?
How deep were the monitoring wells that
were installed?
The fact sheet indicates that there were also
some solvents found at the site.
Is the estimated time to complete the
alternatives in years or months?

After the soil is thermally treated, why is it
not placed back in the excavation?

So, thermally treated soil is still considered
contaminated soil?

In the feasibility study, it mentioned that an
explosive training device was found at one
of the sites.  Is there a possibility of
explosives at this site or is that remote?
Onsite treatment for the debris was selected to avoid hauling containers of pesticides through communities to a disposal
area.  The cost differential was not significant, and because of the positive aspect of treating the waste at the source, it was
determined to be more appropriate.

Just the soil.  During an earlier field investigation (1987) two groundwater monitoring wells were installed at Site 11.
Groundwater samples collected at both monitoring wells indicated no pesticide contamination in the groundwater. The
overall Remedial Investigation and Feasibility Study program is designed to install additional monitoring wells to further
characterize soil and groundwater contamination at the site.

The screened Interval of the monitoring wells were from 10 feet below ground surface to 40 feet below ground surface.
Additional monitoring wells will be screened over a shorter interval across the water table surface and at the deeper parts of
the surficial aquifer.

During an earlier investigation conducted in  1987, some solvents were found in two soil samples.  The solvents that were
found in the soils included toluene,  a common petroleum product that could have been used to cut or dilute and process the
pesticides; 1,1-trichloroethane (TCA), another common solvent that could have derived from practices other than the
pesticide operation; and methylene chloride, used commonly as a paint thinner and paint stripper, and may be derived from
that type of waste disposal practice. The concentrations of these chemicals in the soil were very low; in the order of 20 to 40
micrograms per kilogram.

The estimated time to complete each of the alternatives for the interim remedial action at site 11 is 5 weeks.


After offsite thermal treatment of the soils is completed, the soil is still considered a hazardous waste.  Regulatory
requirements state that the soils must go into a permitted hazardous waste landfill.

In the hazardous waste regulatory system, thermally treated soil is still considered hazardous for land disposal purposes.
Total petroleum hydrocarbon contamination without the hazardous waste constituents, are treated in a different manner.

It is a remote possibility that unexploded ordnance will be encountered at this site. However, part of the cleanup operations
for all alternatives includes a provision to handle unexploded ordnance, If encountered.

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fe'r-
            Responsiveness Summary-continued

        Site 11 Source Control Remedial Alternatives

                       NAS Cecil Field, Florida
                        Comment
                                                  Response
         QUESTIONS FROM THE PUBLIC MEETING
         (continued)

         How will the soil that comes out of the
         ground be classified? What type of F
         codes, U codes, K codes, apply?

         Do you run an analytical test on all the soil
         before it goes offsite in order to classify it?

         From your investigations, how long have
         the drums that were filled with pesticide
         containers been sitting there?

         Based  on what you found so far, what is
         the estimated volume, in gallons, that was
         likely disposed of at Site 11 ?
At least one U-type waste, 1,2,-dibromo-3-chloropropane (U-66), has been identified to be present at the site.  If we find
a U-type listed waste, then that would be a Resource Conservation and Recovery Act (RCRA) hazardous waste and must
be managed accordingly. Otherwise, the soil would be evaluated based on its hazardous characteristics.

Yes.


Overpacked drums have been sitting aboveground since the end of the field investigation (October 1993).
In the test pits, 41 empty containers (1- to 55-gallon containers), 7 full or partially full containers, and 3 50-pound bags of
yellow powder were uncovered. Because it was an undocumented disposal operation, it is difficult to determine an
accurate volume in gallons of what was deposited.

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